Proposed salmon farming standards ignore environmental impacts

January 20, 2011

Environmental groups object to efforts to describe weak standards as an "ecolabel"

VANCOUVER — Salmon farming standards being proposed by an industry trade association don't address the most critical environmental and social threats resulting from current open net pen salmon farming — particularly on Canada's West Coast, environmental groups said Thursday.

The warning, issued by the David Suzuki Foundation and Living Oceans Society, came on the final day for public input into the Global Aquaculture Alliance's (GAA) draft standards for salmon farming. The proposed standards are being criticized by both groups as being too weak to support any claim of environmental or social responsibility, or sustainable salmon farming.

"The GAA has proposed a set of standards that primarily require that the certified operation has complied with the law and is trying to do a good job," said Jay Ritchlin, director of the marine and freshwater conservation program at the David Suzuki Foundation. "While this may offer some value by discouraging the worst farming practices, it shouldn't be confused with an indication of significantly improved social or environmental performance by these aquaculture operations."

The GAA is creating a lot of confusion by promoting the standard as Best Aquaculture Practices (BAP) while also designing a standard that will certify a large majority of existing salmon aquaculture operations globally without any change in operations.

"Suppliers, retailers and consumers who are honestly concerned about the sustainability of the seafood they sell and consume should not be led to believe that this standard satisfies their concerns," said Shauna MacKinnon, sustainable seafood campaign manager at the Living Oceans Society.

The GAA states on page 1 of its standard that "BAP standards...assure healthful foods produced through environmentally and socially responsible means." However, the two groups say that the environmental portion of the proposed standards doesn't meet the bar for two main reasons:

Any salmon farm that essentially complied with government regulation and made some aspirational commitments would qualify for certification. Significant impacts from salmon farming on wild salmon and marine ecosystems have been researched and documented while local and national regulations have been in place. Conforming to regulations that have been demonstrated to be inadequate is not a mark of environmental responsibility.

The GAA standard does not include any provisions to minimize the impact of disease and parasites on wild salmon. This issue, which is the subject of much peer-reviewed science, international research conferences and now a part of a Canadian Federal Commission of Inquiry, is clearly one of the most important impacts to assess in regard to the environmental responsibility of salmon farming, and it is virtually unaddressed in these standards.

"These standards suggest that most of the industry currently operates at a high level of sustainability and has effectively eliminated or minimized its threats to wild salmon and ecosystems. And that is simply not the case," Ritchlin said.

The groups say there is also a significant design flaw in the certification. GAA shrimp certifications, for example, have been predominantly granted to products that were assessed at the processing plant, not at the shrimp farm where the majority of environmental impacts occur. In other words, the GAA certification could apply to a processing plant rather than a farm site, and therefore doesn't clearly tell the buyer whether a product's performance was evaluated at the most relevant time and place.

"GAA certification might help buyers filter out the very worst actors from the supply chain, but that is not the same as achieving an acceptable level of sustainability," MacKinnon said.

Both the David Suzuki Foundation and Living Oceans Society are involved in multiple processes aimed at developing standards, improving technology and conducting assessments for sustainable seafood, including aquaculture operations. They note that the GAA's standard-setting process and governance, while improved from several years ago, is still the one most closed to stakeholder input at key stages.

They are asking the GAA to clearly identify that the standard is not an indication of significant social and environmental improvement over basic regulatory compliance and to remove the option of certifying a product that has not been assessed throughout its production chain. The groups are also urging seafood buyers and sellers not to consider GAA farmed salmon as meeting commitments they've made regarding the purchase of sustainable seafood.

Background: Summary of official comments submitted by the David Suzuki Foundation and Living Oceans Society to the Global Aquaculture Alliance on its Draft Farmed Salmon Standards.

General Points

We do not accept the claim that farms that meet these standards are environmentally and socially responsible. There is simply not enough strength in the current standards proposal or to the certification process for the GAA's Best Aquaculture Practices program to justify the claim of "responsible production" at this time. The scope of the standards includes an intention to support continuous improvement, but none of the standards achieves this.

The standards outlined in the draft primarily rely on government regulation. This is not acceptable for an ecolabel as it overlooks the fact that it is the failure of adequate government regulation that has created the need for an ecolabel in the first place. As it is, there is an absence of effective government regulation for several of the most important negative impacts of salmon farming.

Technical Points

Community Impacts

We believe the community protection standards are far too weak to be classified as "responsible". Most importantly, there is no mention of First Nations issues nor are their standards to address traditional land use, legal rights to traditional food sources, culturally appropriate consultation or conflict management.

Sediment and Water Quality

The Sediment and Water Quality standards rely exclusively on the requirements set in local operating permits. There are no standards that require best international practices to be met or continuous improvement over time. While monitoring is required, with a mention of the eventual creation of a BAP database, no actions need to be taken based on these results other than following local regulations.

Fishmeal and Fish Oil Conservation

For a standard that intends to promote environmentally and socially responsible practices the impact of feed ingredients must be more seriously addressed to reduce the dependence on wild fish and create incentives for continuous improvement over time. The standards as currently written are weak in terms of definitions—"sustainable fisheries" is not defined in the preamble and is not required in the standards, the implementation time of three years to meet the feed-mill standards is too long and the traceability requirements too low. The calculation for the fish in: fish out ratio allows fishery and aquaculture by-products to be excluded, which makes the allowance of 2.5 fish in to fish out much higher than current industry best practices.

Escapes

Under these standards, multiple escapes are allowed that could equal 20 per cent or more of a farm's production. This would be the equivalent of more than 200,000 fish at a typical farm. This is not "responsible production".

Predator Killing

The standard creates the possibility that IUCN red-listed species can be killed if permission is granted by the regulator. The regulator is not a credible source on this issue and cannot be relied on to assess whether species can be killed. Any killing of IUCN red-listed species is unacceptable and any farm that conducts this must be removed from the certification scheme immediately.

Disease Impacts

The issue of disease transfer from salmon farms to wild salmonids is one of the most important local impacts of the salmon farming industry. The current draft relies only on government regulation and the use of veterinarians to address this issue. This is not "responsible" production and in our view does not make the worst actors ineligible for certification, which is our understanding of the scope of these standards. As they stand, these standards will not reduce the current impact of salmon farming on wild salmonids. While we recognize the challenge of developing standards on this issue, the lack of acknowledgement by the current draft is a serious credibility concern in our view and makes any claim that certified operators are environmentally responsible misleading.